Privacy Policy — wc444

1. Introduction

This Privacy Policy ("Policy") describes how wc444 ("wc444", "we", "us", "the Platform"), operating through the website at wc444.cam, collects, processes, stores, shares and protects personal data relating to registered players, prospective users and website visitors ("you", "Data Subject").

wc444 is committed to handling personal data with integrity, proportionality and transparency. We collect only what we need, use it only for the purposes described in this Policy and take reasonable steps to keep it secure. This Policy is written in plain English so that every player — whether based in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar or elsewhere — can clearly understand how their information is handled.

By accessing the wc444 Platform, creating an account or using any of our services, you acknowledge that you have read and understood this Policy. If you do not agree with the practices described herein, you must not use the Platform and should contact us to request Account closure and data review.

This Policy should be read alongside our Terms & Conditions and Responsible Gambling Policy, each of which is incorporated by reference.

2. Definitions

The following definitions apply throughout this Policy:

• "Personal Data" means any information that identifies or could reasonably be used to identify a living natural person, either directly or indirectly.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, combination, restriction or deletion.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data. For this Platform, the Data Controller is wc444.
• "Data Processor" means any entity that processes Personal Data on behalf of the Data Controller.
• "Data Subject" means the individual to whom Personal Data relates — in this context, you, the Player or website visitor.
• "KYC Data" means identity verification documents and associated data submitted by a Player as part of the Know Your Customer process.
• "Cookies" means small text files or similar tracking technologies placed on a device when a user accesses a website.
• "Consent" means a freely given, specific, informed and unambiguous indication of the Data Subject's agreement to the processing of their Personal Data for a stated purpose.

3. Data Controller

The Data Controller responsible for the Personal Data processed through the wc444 Platform is the operator of wc444.cam. For all data-related enquiries, requests or complaints, please contact us using the details provided in Section 17 of this Policy.

Where wc444 engages third-party service providers to process data on its behalf — such as payment processors, identity verification providers or platform infrastructure suppliers — those parties act as Data Processors operating under binding data processing agreements that prohibit unauthorised use of your information.

4. Data We Collect

4.1 Registration Data

When you create a Player Account, we collect the following information:

• Full legal name as it appears on official identity documents;
• Date of birth (to verify age eligibility);
• Email address;
• Residential address (city, province, postal code and country);
• Chosen username and encrypted password;
• Phone number, where provided.

4.2 Identity Verification (KYC) Data

To comply with identity verification requirements, we may collect copies of:

• Government-issued photo identification (e.g., a valid CNIC or passport);
• Proof of residential address (e.g., a utility bill or bank statement dated within three months);
• A selfie or liveness-check image or video confirming the identity of the Account holder;
• Payment method ownership evidence (e.g., a screenshot of an Easypaisa, JazzCash or bank account statement showing the account holder's name) — these references are illustrative of familiar Pakistani payment methods only and do not imply that those providers endorse or support gambling.

4.3 Transactional Data

We record all financial transactions associated with your Account, including deposit amounts, withdrawal requests, payment method identifiers (masked), transaction timestamps, currency (PKR or equivalent) and processing status.

4.4 Gaming and Betting Activity Data

We maintain records of your gaming and betting activity on the Platform, including game sessions, wager amounts, outcomes, bonus usage, wagering requirement progress and account balance history. This data supports responsible-gambling monitoring, dispute resolution and regulatory compliance.

4.5 Technical and Device Data

We automatically collect the following technical data when you access the Platform:

• IP address and approximate geolocation derived from it;
• Device type, operating system and browser version;
• Session timestamps, pages visited and actions taken on the Platform;
• Referral source (the URL from which you arrived at wc444.cam, if applicable);
• Cookie identifiers and session tokens.

4.6 Communications Data

We retain records of communications between you and wc444 support, including live chat transcripts, email correspondence, support tickets and, where applicable, records of responsible-gambling tool activations, self-exclusion requests and cooling-off period activations.

5. Purpose & Legal Basis for Processing

wc444 processes Personal Data only where a lawful basis exists. The following table summarises our primary processing purposes and their corresponding legal bases:

6. Data Sharing

6.1 Authorised Service Providers

wc444 may share your Personal Data with third-party service providers who assist in operating the Platform. These may include identity verification providers, payment processing infrastructure, customer support platforms, fraud detection services and cloud hosting providers. All such providers are bound by contractual data processing agreements restricting their use of your data to the specified purposes only.

6.2 Legal and Regulatory Disclosure

We may disclose your Personal Data to competent authorities, law enforcement bodies or regulatory agencies where we are required to do so by applicable law, court order or regulatory mandate. This includes disclosure in connection with anti-money-laundering investigations, fraud enquiries or other legal proceedings.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, sale of assets or insolvency proceeding involving wc444, your Personal Data may be transferred to the acquiring or successor entity as part of that transaction. We will endeavour to notify affected Players where such a transfer is material and affects the terms of this Policy.

6.4 No Sale of Personal Data

wc444 does not sell, rent, lease or trade your Personal Data to third-party advertisers, data brokers or marketing companies. Any claim by a third party that they have purchased or licensed your data from wc444 should be treated as fraudulent and reported to us immediately.

7. International Data Transfers

The wc444 Platform may be operated through infrastructure hosted in jurisdictions outside Pakistan. Where Personal Data is transferred internationally, we take appropriate steps to ensure that such transfers are conducted in accordance with applicable data protection requirements, including the use of contractual safeguards where required.

By using the wc444 Platform, you acknowledge that your Personal Data may be processed and stored in countries other than Pakistan. These countries may have data protection laws that differ from those applicable in Pakistan.

8. Data Retention

We retain Personal Data for as long as your Account remains active and for such further period as is necessary to comply with applicable legal obligations, resolve disputes, enforce our Terms & Conditions and meet our AML and fraud-prevention requirements. In general:

• Account registration data and gaming activity records are retained for a minimum of five (5) years following Account closure;
• KYC documents and identity verification records are retained for a minimum of five (5) years from the date of Account closure or the date of the last transaction, whichever is later, in accordance with AML obligations;
• Financial transaction records are retained for a minimum of five (5) years following the relevant transaction;
• Support communications are retained for the duration of your Account plus a reasonable post-closure period for audit purposes;
• Anonymised or aggregated analytics data may be retained indefinitely as it does not constitute Personal Data.

When retention periods expire and no legal basis for further processing exists, Personal Data is securely deleted or irreversibly anonymised.

9. Data Security

wc444 implements appropriate technical and organisational measures to protect Personal Data against unauthorised access, loss, destruction, alteration or disclosure. These measures include:

• TLS/HTTPS encryption for all data in transit between your device and our servers;
• Encrypted storage of sensitive Account credentials and payment identifiers;
• Access controls restricting internal access to Personal Data on a need-to-know basis;
• Security monitoring and logging of access to sensitive data systems;
• Regular security reviews of platform infrastructure and third-party integrations.

Notwithstanding these measures, no digital transmission or storage system is absolutely secure. You are responsible for maintaining the security of your Account credentials and should notify wc444 immediately if you suspect any unauthorised access to your Account.

10. Cookies & Tracking Technologies

10.1 What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They allow the website to recognise your device on return visits and provide functionality such as keeping you logged in, remembering preferences and gathering aggregated usage data.

10.2 Cookies Used by wc444

wc444 does not deploy advertising tracking cookies or cross-site behavioural profiling technologies. You may control cookie preferences through your browser settings; however, disabling essential cookies may prevent certain Platform features from functioning correctly.

11. Your Data Rights

Subject to applicable law and any overriding legal obligations (such as AML retention requirements), you may exercise the following rights with respect to your Personal Data held by wc444:

• Right of Access: You have the right to request a copy of the Personal Data we hold about you, along with information about how it is processed.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete Personal Data. For some corrections, we may require supporting documentation.
• Right to Erasure ("Right to be Forgotten"): In certain circumstances, you may request deletion of your Personal Data. This right is subject to exceptions where we are required to retain data by law — for example, AML record-keeping obligations will override a deletion request for transaction data during the applicable retention period.
• Right to Restriction of Processing: You may request that we restrict the processing of your data in specific circumstances, such as while a rectification request is under review.
• Right to Object: Where processing is based on legitimate interests, you may object to that processing. We will assess whether our legitimate interests override your objection on a case-by-case basis.
• Right to Data Portability: Where processing is based on consent or contract and carried out by automated means, you may request receipt of your Personal Data in a structured, machine-readable format.
• Right to Withdraw Consent: Where processing is based solely on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before the withdrawal.

To exercise any of the above rights, please contact us at the address in Section 17. We will respond within a reasonable timeframe and may need to verify your identity before actioning a request. No fee is charged for genuine rights requests unless requests are manifestly unfounded or excessive.

12. Minors

The wc444 Platform is strictly for adults aged 18 or over — or the higher minimum required by the operator/license jurisdiction. We do not knowingly collect Personal Data from individuals below the applicable minimum age. If we become aware that a minor has registered an Account or submitted Personal Data, we will promptly close the Account, forfeit any associated Balance and securely delete the personal data in accordance with our retention policy.

If you believe that a minor has used the wc444 Platform or submitted personal information, please contact us immediately at [email protected].

13. Third-Party Links and Services

The wc444 Platform does not contain links to external third-party websites outside of the navigation and footer structure defined for this site. Should you navigate to any external site independently, please note that wc444 is not responsible for the privacy practices or content of those sites. Each external website has its own privacy policy that you should review separately.

14. KYC & Verification Data — Special Handling

KYC documents constitute sensitive Personal Data requiring heightened protection. wc444 applies the following specific safeguards to KYC data:

• KYC documents must be submitted exclusively through the Platform's secure HTTPS verification portal. Never send identity documents through general email, live chat, WhatsApp or social media.
• Access to KYC documents is restricted to authorised compliance personnel only, on a strict need-to-know basis.
• KYC documents are stored in encrypted form and are not used for any purpose other than identity verification, age confirmation, AML compliance and fraud prevention.
• Third-party identity verification providers engaged by wc444 are bound by data processing agreements prohibiting use of KYC data beyond the contracted verification purpose.
• Falsified documents constitute fraud and will be reported to relevant authorities. wc444 cooperates fully with law enforcement in connection with document fraud.

15. Pakistan-Specific Notice

Players accessing the wc444 Platform from Pakistan should be aware of the following:

• No Pakistani government endorsement: wc444 does not claim that its data processing practices are approved, regulated or supervised by the Government of Pakistan, the Pakistan Telecommunication Authority (PTA), the State Bank of Pakistan, the Federal Investigation Agency (FIA) or any other Pakistani authority.
• Payment references are contextual only: Any reference to Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah in this Policy or elsewhere on the Platform is purely to provide familiar context for Pakistani players. These references do not imply that such providers endorse, support or permit gambling transactions. Players should review the terms of their own financial service providers before using them in connection with gambling activities.
• Local law: Pakistan's data protection and privacy framework continues to develop. The Personal Data Protection Bill (PDPB) and associated legislation may impose obligations on both data controllers and data subjects. This Policy does not constitute legal advice regarding your rights or obligations under Pakistani law. If you have concerns about data privacy under Pakistani law, please seek independent legal advice.

16. Changes to This Policy

wc444 reserves the right to update or amend this Privacy Policy at any time. Material changes — those that meaningfully affect how we collect, use or share your Personal Data — will be communicated to registered Players via the email address associated with their Account and/or by a prominent notice on the Platform prior to the change taking effect.

Minor changes, such as clarifications or corrections that do not alter the substance of data processing practices, may be made without specific notification. The "Last Updated" date at the top of this Policy will reflect any revision. Continued use of the Platform following publication of an updated Policy constitutes your acceptance of the revised terms.

We recommend reviewing this Policy periodically. Archived versions of previous policies are available upon request.

17. Contact Us

For any questions, concerns, data access requests, rectification requests, complaints or other privacy-related enquiries, please contact the wc444 data team: